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Law School Case Brief

Flood v. Kuhn - 407 U.S. 258, 92 S. Ct. 2099 (1972)


Professional baseball is a business and it is engaged in interstate commerce. With its reserve system enjoying exemption from the federal antitrust laws, baseball is, in a very distinct sense, an exception and an anomaly. Even though others might regard this as unrealistic, inconsistent, or illogical, the aberration is an established one. It is an aberration that has been with us now for half a century, one heretofore deemed fully entitled to the benefit of stare decisis, and one that has survived the court's expanding concept of interstate commerce. It rests on a recognition and an acceptance of baseball's unique characteristics and needs. Other professional sports operating interstate are not so exempt.


In accord with professional baseball's reserve system, plaintiff Curtis C. Flood, a major league baseball player, was traded to another major league team without being consulted about the trade. Flood complained to defendant Bowie K. Kuhn, the Commissioner of Baseball, and sought to be made a free agent to bargain with any other major league team. After denial of his request, Flood filed a lawsuit against Kuhn and others in federal district court challenging baseball's reserve system as, inter alia, violative of federal and state antitrust laws. The district court found for Kuhn, and the court of appeals affirmed. Flood was granted a writ of certiorari.


Could Flood assert an antitrust claim against professional baseball?




The Supreme Court of the united States affirmed the appellate court's judgment. The Court ruled that although baseball was a big business engaged in interstate commerce, Court precedent dictated that the reserve system was exempt from federal antitrust laws. Any change in the long-established judicial exemption of professional baseball, unlike other professional sports, from the federal antitrust laws, was a matter for Congress, not the Court. Flood's state antitrust claims failed, the Court ruled, because granting the relief sought would conflict with federal policy and national uniformity.

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